Residence tie breaker rules determine tax residency by centre of vital interests, then mutual agreement or place of effective management. The Convention defines resident status by domestic tax criteria: India treats residents as persons liable to tax by domicile, residence, place of management or similar criteria; Bulgaria treats individuals who are nationals and legal persons with head office or registration in Bulgaria as residents. Dual resident individuals are allocated to the State of their centre of vital interests, with unresolved cases settled by mutual agreement of competent authorities; dual resident entities are resident where their place of effective management is situated.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Residence tie breaker rules determine tax residency by centre of vital interests, then mutual agreement or place of effective management.
The Convention defines resident status by domestic tax criteria: India treats residents as persons liable to tax by domicile, residence, place of management or similar criteria; Bulgaria treats individuals who are nationals and legal persons with head office or registration in Bulgaria as residents. Dual resident individuals are allocated to the State of their centre of vital interests, with unresolved cases settled by mutual agreement of competent authorities; dual resident entities are resident where their place of effective management is situated.
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